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Preamble: Understanding Energy Performance Certificates (EPCs)

Energy Performance Certificates (EPCs) were introduced in the UK as part of a broader strategy to
improve the energy efficiency of buildings. These certificates provide a detailed report on the
energy efficiency of a property, including its potential environmental impact through carbon
dioxide (CO2) emissions. Originally designed as a tool to encourage property owners and occupiers
to make their buildings more energy-efficient, EPCs are now a legal requirement whenever a property
is built, sold, or rented.

Currently, EPCs serve several purposes. They provide a standardised measure for comparing the
energy efficiency of different buildings, offer guidance on how to improve energy performance, and
are used by governments to monitor and regulate the energy performance of the national building
stock. However, as their usage has expanded, concerns have arisen that the EPC system is
increasingly being compromised by the varying interests and requirements of its uses.

To ensure that EPCs remain relevant and effective, reforms are necessary. These reforms should
focus on updating the metrics used, improving the accuracy and relevance of the assessments, and
ensuring that EPCs can support the UK’s future energy and environmental goals.

Many of these recommendations should be market-tested with consumers before being introduced, e.g.
research has shown people don’t always understand percentages, and some of the suggested metrics
could lead to more confusion rather than reducing it.

EPC Validity
This is currently set at 10 years; a validity period that is arbitrary and does not serve
regulation or the need to understand the performance of our building stock in the UK. PEPA insists
this is reduced.
• 3 years is ideal
• 5 is acceptable and falls into line with a other processes such as stock condition and proposed
MEES validity periods.

EPC Triggers
Currently an EPC is required when a property is marketed for sale or rental. This must be provided
within 28 days of marketing, ideally within 7 days.
EPCs are also used by local authorities, some government grants (e.g. BUS) and incentives. However,
unless stated, they can use an EPC that could be as much as 10 years old as
there isn’t a trigger to update it.

PEPA feels a new EPC should be triggered when the previous EPC is no longer reflective of
the property – examples include:

Every time significant change occurs, such as:
o Work is completed that requires Building Control (BC) sign-off
o Extensions – as part of BC sign-off process
o New heating system installation

PEPA also strongly recommend that EPCs should be used for every government scheme. The fact that
this isn’t required currently means that the UK is denied up to date information on its building
stock and the improvements that occur to them. We also strongly recommend that where a pre-works
EPC is completed, the post-installation EPC can be completed without a site visit; instead using
the evidence generated by a PAS 2030 installer to confirm the measures installed. This would save
time, cost and carbon but would ensure that the improvements were included in the EPC database.
Predictive energy assessments are currently created prior to approval and construction starting for
new dwellings. They are vital to the approvals process, yet these are not lodged on the central
register by a competent and accredited person. This must change.

Methodology
PEPA has long been asking for more investment in the methodologies associated with EPCs.
Methodologies need to be kept up to date with regulation changes AND technologies and there needs
to be a better way of introducing the latter than the current Appendix Q route, which is
underutilised and too slow and burdensome to be effective for innovation.

PEPA is interested in the Home Energy Model as it looks to address these challenges and create a
more accurate set of calculations, but we remain concerned that without our members oversight in
development of the engine(s) and wrappers, results won’t be fully scrutinised and peer reviewed.

PEPA would also like to see the government allow measured energy performance results to be used
within the methodology. In SAP and in the soon to be released RdSAP 10, air pressure test results
can be accepted by the assessor and used to improve the accuracy of an assessment, and PEPA
believes that adoption of MEP will help to address the performance gaps and also act as a feedback
loop to improve the underlying defaults and assumptions used within RdSAP.

Metrics and contents of the EPC

The current EPC is now an online webpage per report and not a PDF or paper document. This is real
progress. However, the metrics that appear on it are not always understood or helpful, particularly
on the Domestic EPC and particularly as we look at Net Zero journeys.
It is essential to ensure that metrics appearing on the EPC are useful and well explained.

The current Domestic EPC headline ‘metric’ is the Energy Efficiency Rating (EER), and this is
weighted by the fuel costs present at the property. This is helpful when helping viewers compare
one property with another for the running costs and helps with fuel poverty, but we don’t believe
many stakeholders realise this. Some stakeholders, especially those off the gas grid feel this is
unfair, especially in light of future Minimum Energy Efficiency Standards.

PEPA believe that another metric that already exists; the Environmental Impact Rating (EIR) which
uses Carbon emissions should be equal to the EER.

Indeed, both the total Energy demand and HTC figures calculated presently could also be featured
with prominence.

Scotland recently consulted and explored if Fabric efficiency as a new metric has merit, and PEPA
believes it does.
Irrespective, all metrics should be easy to find and understand, and when they apply to funding &
regulation.

Recommendations

Recommendations on EPCs is a complex subject and there are several ways to improve the current
implantation. Ideas include:

• Present all feasible recommendations
• Consider removal of savings in £’s and move to use a % improvement
• Make the recommendations interactive
• Use updated fuel prices at the time of viewing the EPC (ensure it is always useful and valid
when exploring recommendations).
• Use updated carbon emissions factors at the time of viewing the EPC (as above)
• Ensure the viewer gets up-to-date info/metrics for each possible/viable recommendation
• Let the customer prioritize based on their needs
• Improve the estimated cost of a measure – e.g. varying by square meterage for insulation
measures; the data already exists in the dataset, or via calculation. Wall, floor and roof areas
can be derived from the assessment and used to calculate more accurate measured installation costs.
Costs of measures plus local labour costs could be updated regularly via PCDB or another database
file for example. This would ensure that when a stakeholder views an EPC, they can put more faith
in the information and guidance contained within the certificate
• Allow the user/stakeholder to bring in actual occupancy & fuel prices & smart meter data and
then have the ability to remodel their recommendations to better reflect their actual usage of the
property.

Qualifications, training and competency
We are predominantly referring to the DEA qualification here. The current DEA qualification is out
of date, it was last revised fully in 2012 and the methodology, the EPC and regulation has changed
since then. It is missing core components that underpin the industry. PEPA recommends the
following:

• The NOS from c.2012 needs to be rewritten – the current NOS still links to RdSAP
9.91 and Green Deal
• Focus on new methodologies – RdSAP 10 and Home Energy Model (when appropriate)
• Deeper understanding of Climate Change and how it will impact upon building stock
• Bring in PAS 2035 and Retrofit Standards for context and direction of travel
• The context also needs to focus on Net Zero & Decarbonisation and how EPCs, and the improvements
to the energy performance of buildings is explained
• An upstanding of the importance of ventilation and condition aspects would be valuable, in
particular damp, condensation and mould.
• A deeper understanding of Electrification of heat and other decarbonisation journeys, along with
the ability to identify fundamental electrical system attributes.
• Knowledge of demand Side Response tariffs and smart tariffs
• Summer overheating and the impact of a hotter, wetter climate in the UK

PEPA strongly believes that in order to improve the competency in the industry, those already
practicing could achieve additional competency via an upskill. Learners in progress would need to
complete existing training plus upskill, and all new learners would need to be trained on the
updated course.

Quality
Schemes spend a large majority of their resource on Quality Assurance and PEPA believe that the QA
processes have improved and become more sophisticated over the years, especially with the
introduction of Smart Auditing. However, there are areas that need addressing. Schemes would like
to do more auditing that is effective at correcting malpractice and even detecting bad practice. To
do this, we need to be able to easily and effectively see trends in data and having suitable direct
access to data from the EPC registers would prove helpful here, as well as enabling further
enhancements to Smart Auditing, e.g. checking against previous EPCs for the property.

PEPA also welcomes better feedback loops from industry to help schemes and the working groups that
they run to modify QA processes and targeted/risk based smart auditing.

PEPA also strongly recommends that government require that all assessments have stronger minimum
evidence requirements which will assist the QA process. For example, it makes a lot of sense to require all assessors to produce an electric site plan in future.

One type of auditing that has always existed in our armoury is site visits. These can be helpful in
retrospectively detecting error but are very expensive and resource intensive to achieve and if
necessitated at scale would most certainly add cost to the industry and to the consumer. We do feel
there is a place for technology in this regard.

We need to be very careful when considering the improvements that could be made to the
QA requirements of our industry.

In April the Official Journal of the European Union published the full details of the fourth iteration of the bloc’s Energy Performance of Buildings Directive (EPBD). In this blog, Andrew Warren, chair of the British Energy Efficiency Federation explores the significance of this Directive, and the divergence emerging with UK policy.

Over the past twenty years, this single Directive has had more impact upon minimising energy wastage in the 24bn square metres of European Union buildings than any other initiative. Its new objective is by 2030 to double the number of deep energy renovations currently undertaken across Europe, to cut current final energy consumption by 14% and heating and cooling by 18%.

Not for the UK

The first three versions of the EPBD remain operational under UK law. In truth, practically all of the measures currently helping to improve the energy efficiency of the buildings we live and work in have come as a result of this Directive, because we had been members of the European Union.

But, as yet these latest set of improvements won’t apply to anybody living or working in the UK, although they will in other non-EU states like Norway and Switzerland.

Also in April, the annual international gathering of building control professionals, ASHRAE, met for three days in Madrid.  I was invited to be a keynote speaker. I swiftly gathered that this was because, at the start of this century, I had been appointed by the Industry Department of the European Commission to chair an intergovernmental and inter professional task group on Sustainable Construction & Energy Efficiency. Which came out with a whole set of (then) radical ideas to improve the energy performance of buildings. 

Practically all of these then became the basis for the original version of the European Energy Performance of Buildings Directive. The new version was positively the hottest topic of the event, because no other OECD member has yet developed such a detailed legal blueprint for improving energy usage in buildings.

Let me just run though the initiatives which have already sprung directly from this Directive, and which still officially apply in the UK.

Introducing energy performance labels

The entire concept of having a comparative label measuring the running costs of a building was mandated. The original directive ensured creation of an “energy performance certificate” (EPC). It had to be made available to prospective occupiers not just when a building is sold, but whenever a building’s occupants change following the granting of a new lease.

It must include advice on the most cost-optimal improvement options available. All advertising must include information on the rating, between A for (admirable) to G (for ghastly). Note the use of that phrase “cost optimal”, rather than just “cost effective”. That signifies a desire to reflect the full lifetime benefits of including any specific measure, rather than restricting improvement recommendations to the limiting concept of commercial “payback times”.

To ensure quality assurance of certificates, an independent control system was created to verify the validity of both energy performance certificates and heating/cooling systems.

Additionally, any building occupied by a public authority, to which members of the public have access, must display an energy certificate “in a prominent place”, and brought up to date each year. Initially such ratings were to be seen in every public building in the UK. This had been an excellent way for voters to monitor just which public authorities are being frugal, and which profligate. It does seem that, ever since Brexit, an absence of overt oversight by central government has led to much anecdotal evidence of an increasing failure to comply, including even in several central Government departments like the energy department itself. An authoritative survey of compliance is urgently required.

The directive also mandated such key issues as regular inspections of air conditioning systems, of intelligent (or smart) metering systems, and facilities for electric vehicle charging. All these areas are being strengthened in the latest version.

Net zero buildings

Building codes for new buildings needed to be upped every 5 years, a timetable the UK adhered to up until 2015 – when plans to deliver nearly net zero buildings (required under article 9) were unilaterally dropped on a whim of then Chancellor George Osborne. The new EPBD mandates all publicly funded buildings to be absolutely net zero by 2028, and those privately built by 2030. All new buildings are to be “solar ready.”

Britain still has no official benchmark for net zero homes. “If anybody is saying that their building is net zero at the moment, they may be doing that with good intentions. Or it may be something more mythical. The problem is, without a clear standard that allows people to make a credible claim, anything can be challenged,” says Smith Mordak, the chief executive of the UK Green Building Council. The industry body has been working with over 500 organisations to come up with the UK’s first Net Zero Carbon Buildings Standard. A draft version is due this summer.

Mordak agrees it is staggering that no net zero standard exists. “We have known that climate change is real for some time now,” she says wryly. “The barrier is there not being a clear signal from government that, yes, this is important. It is very, very difficult for the industry to adopt a credible pathway to net zero without those clear signals.”

The new version of the EPBD concentrates primarily upon existing buildings, largely because 85% of those we shall be using in 2050 are already constructed. Each government is now charged with updating a strategic Building Renovations plan for delivering energy efficiency, including any financial incentives and penalties- again, a long established EPBD requirement.  The last vaguely equivalent UK plan was issued back in 2014.

These strategic renovation plans will be created using an identical template, with national targets and key mandatory indicators. Importantly all of these comparative details will be public documents, giving voters the information to reward or to chide

Critically, and at last, building passports will be created- as originally recommended by my Sustainable Construction task group over 20 years ago. This will provide practical information about energy saving artefacts in each individual building, of direct use both to building professionals, and to administrators. This information will be recoded in a national database with easy access to relevant parties, and new provisions to ensure interoperability.  

Commercial buildings are traded goods

 But within these plans, each government is charged with paying particular attention to the non-residential building stock. After all, unlike residences, commercial buildings are frequently occupied by non-national corporations, and so are effectively “traded goods” across frontiers.  Governments are required to identify the worst performing buildings, and to move 16% of these by 2030, and 26% of these by 2033, into the higher performance categories. In EPC terms, it means upping E, F and G ratings to B or even A ratings. A new Smart Readiness Indicator will be required for buildings over 1,000 square metres.

A similar, if less detailed, improvement exercise is required for the housing stock, where currently 43% are classed as being currently in the worst performing part of the stock (below EPC grade C). At least 55% of any identified savings should come from improving this sector.

There are to be no more subsidies of any kind for stand-alone boilers powered by fossil fuels, and “policies and measures” to phase out all fossil fuel boilers by 2040

All of these new requirements have long been common currency amongst building professionals in the UK.  None are yet mandatory. It would make sense for the new UK government to implement at pace all the initiatives which our European competitors are now adopting with enthusiasm.

Andrew Warren is chair of the British Energy Efficiency Federation

Views expressed in this piece and all guest blogs are the views of the author and not necessarily of IEEP UK – [Guest Blog] Are post-Brexit building standards lacking energy? – IEEP UK %

https://www.e3g.org/news/business-and-civil-society-lay-out-deep-concerns-at-uk-pm-plan-to-weaken-net-zero-policies/